Tax on foreign income - main mechanism
How foreign-source income is taxed under each regime
Annual flat tax of EUR 100.000 on all foreign-source income regardless of the amount earned or remitted. No additional Greek income tax on foreign income above this flat amount. Covers income of any type: dividends, capital gains, business income, employment income. Source: Astons.com / ImmigrantInvest 2026
15% tax on foreign income remitted to Malta. Foreign income not remitted to Malta: 0% Maltese tax. Under pure non-dom status (not GRP): minimum EUR 5.000 per year on foreign income above EUR 35.000. Under GRP (non-EU nationals): 15% with minimum EUR 15.000 per year. Source: Stantax Malta / Libertymundo Malta 2026
🇲🇹 Malta Malta's regime is better for high-income individuals. Someone earning EUR 5 million in foreign income pays EUR 100.000 under Greece but only EUR 5.000 (non-dom) or EUR 15.000 (GRP) minimum under Malta - with the balance untaxed if not remitted. Greece's flat tax is only cheaper for modest incomes where 2% of income would exceed EUR 100.000 (above EUR 5 million in foreign income, Greece is cheaper)
Tax on foreign capital gains
Maltese or Greek tax on gains from selling foreign assets
Greece non-dom: capital gains from foreign assets covered by the EUR 100.000 flat tax. No additional Greek tax on any amount of foreign capital gains. Fixed and predictable cost regardless of gains realised
Malta non-dom: foreign-source capital gains are never taxable in Malta, even if remitted. Explicit statutory exemption under Article 4(1) of the Maltese Income Tax Act. 0% regardless of amount, no minimum tax applies to capital gains. Source: Libertymundo Malta 2026
🇲🇹 Malta Malta's 0% on foreign capital gains with no floor charge is superior for investors with large but irregular capital gains events. Greece's EUR 100.000 flat tax covers capital gains but still costs EUR 100.000 per year regardless of whether any gains are realised
Minimum tax cost per year
Minimum annual tax obligation under each regime
EUR 100.000 fixed per year regardless of income level, whether income is generated or remitted. No lower minimum. Source: Astons.com 2026
Malta non-dom (TRP): EUR 5.000 per year minimum on foreign income above EUR 35.000. GRP (non-EU nationals): EUR 15.000 per year minimum. For low-income years or years with no remittance, only the minimum applies. Source: Stantax Malta / Libertymundo Malta 2026
🇲🇹 Malta Malta's minimum annual tax of EUR 5.000 or EUR 15.000 is dramatically lower than Greece's EUR 100.000. For individuals in low-income years or those who do not remit foreign income, Malta is far cheaper
Duration of regime
Maximum years the regime is available
Up to 15 years for the primary Greece non-dom participant. After 15 years the regime ends and standard Greek progressive income tax rates (up to 44%) apply. Source: Astons.com / ImmigrantInvest Greece non-dom 2026
Malta non-dom status: indefinite, as long as the individual is not domiciled in Malta and maintains tax residence. No statutory time limit equivalent to Greece's 15-year cap. TRP and GRP programmes also renewable. Source: Libertymundo Malta / Immigrantinvest Malta 2026
🇲🇹 Malta Malta's non-dom status has no statutory 15-year limit. This provides long-term certainty that Greece's regime cannot match. An individual can maintain Malta non-dom status for decades if not domiciled in Malta
Family member inclusion
Cost of extending the regime to family members
Family members included at EUR 20.000 per person per year. For a family of four (principal plus spouse plus two children): total annual tax approximately EUR 160.000 (EUR 100.000 plus 3 x EUR 20.000). Source: Astons.com Greece non-dom 2026
Malta non-dom (TRP/non-dom): each family member assessed individually on their own income and remittances. Minimum tax per family member may be as low as EUR 5.000 if foreign income above EUR 35.000. GRP: each qualifying property and minimum tax covers the principal applicant and family. Source: Stantax Malta / Libertymundo Malta 2026
🇲🇹 Malta Malta's family extension cost is significantly lower than Greece's EUR 20.000 per family member. For families with multiple dependants, Malta's cost advantage is substantial
Predictability and simplicity
Certainty and administrative simplicity of the regime
Greece: fixed EUR 100.000 per year with complete certainty. No need to track which income is remitted, no tax return complexity around foreign income. Pay EUR 100.000 and all foreign income is fully covered. Administratively simple. Source: Astons.com Greece 2026
Malta: requires tracking of remittances to Malta versus income not remitted. Tax applies at 15% on remitted amounts. Administrative burden of maintaining remittance records. Capital gains always 0% regardless. Minimum tax creates floor certainty. Source: Stantax Malta / Libertymundo Malta
🇬🇷 Greece Greece's flat tax is administratively simpler. No remittance tracking, no categorisation of income types, no complex allocation. Pay EUR 100.000 and all foreign income is covered for the year
Residency requirements
Physical presence requirements to maintain the regime
Must spend at least 183 days per year in Greece to maintain Greek tax residence and access the non-dom flat tax regime. Greece must be the primary place of residence. Investment requirement: minimum EUR 500.000 in Greek real estate or business (or EUR 250.000 via Golden Visa property route). Source: ImmigrantInvest Greece 2026
Malta TRP/GRP: spend at least 90 days per year in Malta (not more than 183 days in any other single country). Property requirement: own (EUR 275.000 purchase in Malta or EUR 220.000 in Gozo) or rent (EUR 9.600 per year in Malta or EUR 8.750 in Gozo). Easier to meet than Greece's 183-day requirement. Source: Stantax Malta / Libertymundo Malta 2026
🇲🇹 Malta Malta's 90-day minimum requirement is far more flexible than Greece's 183-day requirement. Individuals can spend more time in other countries while maintaining Malta non-dom status. Ideal for internationally mobile individuals
Maltese or Greek income tax rate
Tax rate on Maltese/Greek-source income
Greek-source income taxed at standard progressive rates: 9% up to EUR 10.000, 22% on EUR 10.001-20.000, 28% on EUR 20.001-30.000, 36% on EUR 30.001-40.000, 44% above EUR 40.000. Non-dom regime covers only foreign income. Source: Astons.com Greece 2026 / ImmigrantInvest
Maltese-source income taxed at progressive rates: 0% up to EUR 9.100, 15% on EUR 9.101-14.500, 25% on EUR 14.501-19.500, 25% on EUR 19.501-60.000, 35% above EUR 60.000. Maximum 35% rate significantly lower than Greece's 44%. Source: Libertymundo Malta / PwC Cyprus Tax Facts 2026
🇲🇹 Malta Malta's top personal income tax rate of 35% is significantly lower than Greece's 44% top rate. For individuals with Maltese/Greek-source income, Malta is more efficient on domestic income taxation
Inheritance and wealth tax
Exposure to inheritance or wealth tax
Greece has inheritance tax applicable to Greek-situated assets. Rates vary by relationship and asset value. Real estate and investments in Greece potentially subject to inheritance tax. Source: ImmigrantInvest Greece 2026
Malta has no inheritance tax, no wealth tax, no annual property tax. Non-dom residents are additionally not subject to Maltese tax on foreign capital gains. Malta is one of the EU's most inheritance-tax-friendly jurisdictions. Source: Astons.com Malta / Libertymundo Malta 2026
🇲🇹 Malta Malta's complete absence of inheritance and wealth tax is a significant long-term planning advantage versus Greece. For high-net-worth individuals with substantial asset bases, Malta's estate planning efficiency is superior
Investment requirement
Minimum investment required to access the regime
Greece Golden Visa (linked to non-dom): EUR 500.000 in real estate or business investment (EUR 250.000 for specific low-demand areas). Required to establish residency qualifying for non-dom regime. Source: ImmigrantInvest Greece 2026
Malta TRP (EU nationals): property purchase EUR 275.000 (EUR 220.000 in Gozo) or annual rent EUR 9.600. GRP (non-EU nationals): property purchase EUR 275.000 (EUR 220.000 in Gozo) or annual rent EUR 9.600 plus EUR 6.000 non-refundable application fee. No EUR 500.000 investment required. Source: Stantax Malta / Libertymundo Malta 2026
🇲🇹 Malta Malta's property requirement is materially lower than Greece's EUR 500.000 investment threshold. For budget-conscious applicants, Malta is significantly more accessible
EU and Schengen access
Rights and access within the EU and Schengen area
Greece is an EU member state and Schengen zone. Greek tax residency qualifies for Greek residency permit. Golden Visa provides non-EU nationals with EU residency and Schengen travel access. Source: ImmigrantInvest Greece 2026
Malta is an EU member state and Schengen zone. TRP and GRP both provide EU residency. Malta's residency permits grant Schengen travel rights. English as official language. Source: Stantax Malta / Libertymundo Malta 2026
Tied Both countries are EU member states and Schengen zone members providing equivalent EU residency rights and freedom of movement within Schengen
Best profile for each regime
Which type of individual benefits most from each regime
Greece non-dom is best for: individuals with very high foreign income (above EUR 5 million per year where EUR 100.000 flat becomes cheaper than 2% of income), pension recipients (7% special rate), individuals wanting complete administrative simplicity on foreign income, and those seeking lifestyle in the Greek islands or Athens with EU residency
Malta non-dom is best for: individuals with moderate to high foreign income wanting to minimise annual tax cost, investors with large foreign capital gains events, those wanting no 15-year time limit on the regime, internationally mobile individuals comfortable with 90-day minimum stay, families wanting lower per-member extension cost
🇲🇹 Malta Malta wins across a broader range of income profiles. Greece's regime is better only for very high earners above EUR 5 million where the EUR 100.000 flat becomes cheaper than Malta's 15% rate
ⓘ All figures are 2026 confirmed rates. Greece non-dom eligibility requires not having been Greek tax resident for 7 of the previous 8 years and meeting investment requirements. Malta TRP is for EU/EEA/Swiss nationals; GRP is for non-EU nationals. Malta non-dom (pure remittance basis) requires not being domiciled in Malta and meeting the 90-day minimum stay and property requirements. Both regimes cover only the named foreign-income aspects - Greek or Maltese-source income is taxed at standard rates in each country. Always consult a qualified tax adviser in Greece and Malta before making residency decisions.